A few weeks ago, Jack Hooper sat across from Dr. Mehmet Oz and other senior officials at the Centers for Medicare & Medicaid Services (CMS) to talk about the future of what the Trump administration is now calling "CHOICE arrangements." What he heard - and what he pushed back on - tells brokers a good deal about where the defined contribution market is heading and how much political capital is actually behind it.
Hooper is CEO of Take Command, a Dallas-based platform that administers Individual Coverage Health Reimbursement Arrangements (ICHRAs) for employers and guides their employees through individual plan selection. He came away from the meeting cautiously encouraged, but clear-eyed.
"I'm very convinced that at some point we'll look back in America and say it all flipped over to this model," he told Insurance Business Benefits US. "If it takes three years, five years, 10 years - I don't know - but it'll get there."
Hooper welcomed the administration's decision to retire the ICHRA name - "ICHRA sounds like you sneezed," he said - but was blunt about what the rebrand has delivered so far.
"We were hoping with CHOICE that we would see some regulatory or statutory enhancements," he said. "Those haven't come through yet. We've been told they're coming soon, but right now it's just window dressing."
The market is growing regardless. According to the HRA Council's 2025–2026 annual report, more than 20,000 US businesses now offer an ICHRA, a 53 percent increase from 2025, with covered lives surpassing 500,000. The Employee Benefit Research Institute (EBRI) has identified individual market affordability, provider network quality, and implementation complexity as the primary barriers to wider uptake, while its director of health benefits research, Paul Fronstin, told IBB of the risk to employees from wider adoption.
Hooper raised the sharpest of those tensions directly with Dr. Oz, noting that the quality and affordability of CHOICE arrangements depends entirely on a healthy ACA marketplace. The administration has spent years trying to weaken that same marketplace.
"He was like, 'Hey look, we were trying to get rid of the ACA. Now we think we need it,'" Hooper recalled. "So we're going to make it as best we can."
Hooper also pushed the case for restoring Cost-Sharing Reduction (CSR) payments - the federal subsidies that help lower-income Americans cover copays and deductibles, which the first Trump administration cut as part of an effort to destabilize the ACA. Research from both sides of the aisle, Hooper said, now shows that cutting CSR payments actually increases the federal deficit through silver loading.
"If we can just have predictability and restore those things, we can save the federal government money and bring costs down for everybody," he said. He noted that restoring CSR payments now appears in Trump's own healthcare plan - a sign, he argued, that the political conditions for action may be better than they look.
As IBB has reported, 54 percent of benefits brokers have still never sold an ICHRA, according to the TASC 2026 Broker ICHRA Survey, even as employer adoption accelerates and Hooper thinks the window for sitting on the fence is closing.
"Forward-leaning brokers are starting to figure it out," he said. "Brokers that are stuck to 'let me just run quotes' - they're going to get run over. That value is going to fade."
The functional change he describes is significant. Annual requoting largely disappears under a defined contribution model. In its place, brokers need to think like wealth managers - helping employers set contribution levels, adjusting them over a three-to-five-year horizon, and extending service down to the individual employee level rather than stopping at the plan sponsor.
"Our best broker partners have recognized that the decision onus has now moved down to the employee level," he said. "Even if there are thousands of employees, brokers can still educate on which hospitals go where, how it works, and who to call for help. Those brokers are being wildly successful with ICHRA."
Take Command positions itself to brokers as a carrier, not a competitor - installing the ICHRA, handling individual enrollments, and paying a commission comparable to a traditional group plan. But as IBB has reported, broker compensation structures under CHOICE arrangements are not yet standardized across ICHRA administrators, making due diligence on platform selection a critical step before any recommendation.
Hooper's advice to skeptical brokers is to treat ICHRA as a third option alongside fully insured and level-funded - not a replacement for either. And he thinks the employer appetite is already there, as large-employer adoption signals show, with Centene among those scaling internal ICHRA programs as the defined contribution model moves toward the mainstream.
"They don't want to be managing a health plan," he said. "And it's odd that in the US, that's how we've evolved our system. If they can get out of it but still take care of their employees and provide a benefit, they'll jump out right away."
